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Transportation, packaging and supply ...... 3 Road transportation ...... 22 Emergency Action Code (EAC) ...... 51 ADR hazard identification numbers (HIN) or ‘Kemler Code’ ...... 55 Packaging ...... 62

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Supply classification and labelling

There have been significant changes to the legislation that controls how the hazards of chemical products are classified and communicated. The purpose of supply classification and labelling is to consider the end user of a product. It should ensure they have sufficient information on the hazards of products to enable them to fully assess the risks the product presents in the process in which they use the product. This may be an industrial user, such as an employee in the chemical manufacturing industry or a professional user, such as a hair-stylist or professional gardener who uses chemical products as part of their role. The end user could also be a member of the public, as household products such as bleach and washing detergents can also contain hazardous chemicals. The scope of supply regulations are therefore wider than the transportation regulations, and also include a wider range of hazards, particularly for health hazards where long-term or chronic health effects are also considered.

The changes in supply regulations have been driven by the adoption of the United Nations Globally Harmonised System for classification and labelling, typically referred to as UN GHS or just GHS. UN GHS is an international agreement developed to create global standards in two key areas. Firstly, on the criteria for classifying chemicals according to their physical, health, environmental hazards, Secondly on hazard communication requirements through labelling and safety data sheets.

UN GHS is a non-legally binding international agreement; countries, or trading blocks such as the European Union, have to create legislation to implement it. In the EU this has been done through the Classification, Labelling and Packaging of Substances and Mixtures Regulation, EC1907/2006, typically referred to as the CLP regulation.

CLP replaces previous EU directives that set out the requirements for classification and labelling in Europe, the Dangerous Substances Directive 67/548/EEC and Dangerous Preparations Directive 1999/45/EC. These directives were implemented in the UK under the Chemical Hazard Information and Packaging for Supply Regulations, commonly referred to as the CHIP regulations. The overall concept of CLP has many crossovers with the CHIP regulations: the hazards of the products are classified into specific groups and this information is communicated through a label. However there are some differences between the classification groups and the content of the label information.

Comparison of hazard communication under CLP to the CHIP regulations

The label is a primary method of hazard communication under both the old CHIP regulations and under CLP. Table 15 shows how the structure of the labels are effectively quite similar, but there

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Table 15 CHIP and CLP label comparison

CHIP Label CLP Label

Indications of Danger: Signal Word: • Explosive • Danger • Oxidising • Warning • Extremely flammable • (None) • Highly flammable • Very toxic • Toxic • Harmful • Corrosive • Irritant • Dangerous for the environment

Symbols Pictograms

Risk phrases: Hazard statements: • Highly flammable • Highly flammable liquid and vapour • Very toxic by inhalation • Fatal if inhaled • Causes burns • Causes severe skin burns and eye damage

Safety phrases: Precautionary statements: • Keep container tightly closed • Keep container tightly closed • Avoid contact with skin and eyes • Do not get in eyes, on skin or on • Wear suitable protective clothing clothing • Wear protective clothing

How does the GHS classification system work?

GHS splits the hazards from chemical products into three types – physical, health and environmental hazards. Within these hazard types are hazard classes that describe the nature of

This content is only valid at the time of download - 30-09-2021 17:53 4 of 72 the physical, health or environmental hazard. Using physical hazards as an example, the following hazard classes are given:

Explosives Flammable gases Aerosols Oxidising gases Gases under pressure Flammable liquids Flammable solids Self-reactive substances and mixtures Pyrophoric liquids Pyrophoric solids Self-heating substances and mixtures Substances and mixtures that emit flammable gases when in contact with water Oxidising liquids Oxidising solids Organic peroxides Corrosive to metals

Each hazard class is then further divided into a number of hazard categories. These are represented by numbers, and are used to indicate the severity within the hazard class. A hazard category 1 represents the most severe hazard. The severity of the hazard then decreases as the number increase. The table below shows how the hazard categories are differentiated using flammable liquids as an example.

Table 16 Flammable liquids hazard category

Hazard category Criteria

1 Flash point < 23oC and initial boiling point ≤ 35oC

2 Flash point < 23oC and initial boiling point > 35oC

3 Flash point ≥ 23oC and ≤ 60oC

Table 17 below demonstrates when a product has been confirmed to meet the criteria for a hazard class and category. The CLP regulation indicates the pictogram, signal word, hazard statements and precautionary statements that have to be used on the product packaging. For a liquid product with a flashpoint measured at 31oC, and boiling point measured at 60oC the product would be classified as a Flammable liquid, category 2. The regulation then provides the following hazard communication information:

This content is only valid at the time of download - 30-09-2021 17:53 5 of 72 Table 17 CLP hazard and precautionary statements

Pictogram:

Signal word: Danger

Hazard statement: H225 Highly flammable liquid and vapour.

Precautionary statements: • P210 Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking • P233 Keep container tightly closed. • P240 Ground/bond container and receiving equipment • P241 Use explosion-proof electrical/ventilating/lighting/equipment • P242 Use only non-sparking tools. • P243 Take precautionary measures against static discharge. • P 280 Wear protective gloves/protective clothing/eye protection/face protection. • P303 + 361 +353 IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/ shower. • P370 + 378 In case of fire: Use water to extinguish. • P403 + 235 Store in a well-ventilated place. Keep cool. • P501 Dispose of contents/container to …

In practice, a maximum of six precautionary hazard statements should be used on a product label, and the regulation provides further guidance on how to refine the precautionary statements so that an acceptable number are used on the label.

Once the full range of physical, health and environmental hazards of a product have been classified according to the CLP classification rules, a label for the product can be created. The following information must be included on the label:

Name, address and telephone number of the supplier(s) Nominal quantity of the substance or mixture in the package made available to the general public, unless this quantity is specified elsewhere on the package Product identifiers (name)

This content is only valid at the time of download - 30-09-2021 17:53 6 of 72 Hazard pictograms Signal word Hazard statements Precautionary statements

The label must also be in the official language for the country it will be sold in. So for any product supplied into the UK, the language used on the label must be English.

Table 18 below describes how the label used must also meet minimum size requirements.

Table 18 CLP label, minimum size requirements

Minimum dimensions of the label Capacity of package (mm)

Not exceeding 3 litres 52 x 74

Greater than 3 litres, but not exceeding 50 litres At least 74 x 105

Greater than 50 litres, but not exceeding 500 At least 105 x 148 litres

Greater than 500 litres At least 148 x 210

CLP label example

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Links between CLP regulation and dangerous goods transportation regulations.

The UN GHS classification guidelines are issued through a UN document referred to as the purple book. They form the basis for the European supply regulation, the Classification, Labelling And Packaging Of Substances And Regulations (CLP). Diagram 2 below describes the classification rules used by UN GHS, which also form the basis for the classification rules used in transportation regulations:

Diagram 2 Classification rules used by UN GHS

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This ensures that the classification rules match between the different regulations. However, as the supply regulations are written for people who use chemicals as part of their job or members of the public, rather than just for transportation purposes, there are differences in the classification groups included. This is seen most significantly as the long term, or chronic, health effects that are included in the CLP regulation, but not in transportation regulations.

The tables below provide more information on the classification groups included in the CLP and transport regulations.

Table 19 CLP and CHIP classification groups for transportation of hazardous materials

Transport GHS class GHS symbol CHIP symbol Symbol class

Explosive 1

Flammable 2 gases

2 Aerosol

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Gases N/A 2 under pressure

Flammable 3 liquids

Substances that emit flammables 4.3 on contact with water

Oxidising solids, 5.1 liquids and gases

Organic 5.2 peroxides

Transport GHS class GHS symbol CHIP symbol Symbol class

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Acute toxicity 6

Skin corrosion 8 / irritation

Serious eye Not damage / regulated irritation

Respiratory or Not skin regulated sensitisattion

Germ cell Not

mutagencity regulated

Not Carcinogenicity regulated

Reproductive Not

toxicity regulated

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Specific target

organ toxicity

Transport GHS class GHS symmbol CHIP symbol Symbol class

Hazards to the aquatic 9 environment

Two classification groups are included in the transportation regulation but not included in the CLP regulation, as other areas of EU regulation cover these groups: radioactive materials and biological hazards.

Table 20 CLP Non-regulated classification groups

GHS Class Symbol Transport class Symbol

Not regulated 6.2

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Not regulated 7

Regulatory background

The regulatory framework for the global transport of dangerous goods is agreed by the UN Sub- Committee of Experts for the Transport of Dangerous Goods. Its provisions are set out in the UN model regulations (‘Recommendations on the Transport of Dangerous Goods’, commonly known as the orange book), which are revised and republished every two years and form the basis of the internationally agreed mode-specific requirements. The regulations do not apply to the bulk transport of dangerous goods in seagoing or inland navigation bulk carriers or tank-vessels, which is subject to special international or national regulations.

Detailed rules for the international transport of dangerous goods by road are set out in the United Nations Economic Commission for Europe (UNECE) publication known, from its French title, as Accord Dangereux Routier (ADR). The text for each edition of ADR (re-issued every two years) is agreed by a UNECE committee which usually meets bi-annually in Geneva; the UK is represented at these meetings by the Department for Transport, which consults key dangerous goods interest groups before the UK position on the various agenda items is decided. This agreement has no overall enforcing authority; in practice checks are carried out by contracting parties and non- compliance is dealt with by national authorities in accordance with domestic legislation.

Detailed provisions for the international transport of dangerous goods by rail are published under the Organisation Intergouvernementale pour les Transports Internationaux Ferroviaires (OTIF) convention in a document known from as reglement International concernant le transport de marchandises dangereuses par chemin de fer (RID). OTIF is an inter-governmental organisation with a mainly European membership that includes the UK. The RID committee of experts usually meets every two years, at different locations, and the UK is again represented by the Department for Transport. The text of RID is almost identical to that of ADR, varying only to reflect modal differences.

The EU has adopted the UNECE/OTIF rules in a series of directives which extend the scope of ADR and RID to apply to national as well as intra-community transport. A combined directive for the inland transport of dangerous goods (covering road, rail and inland waterways) – 2008/68/EC – is transcribed into UK domestic legislation via The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.

This content is only valid at the time of download - 30-09-2021 17:53 13 of 72 The model regulations lay out the requirements for the carriage of dangerous goods for the specific mode of transport. In summary they are: The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) The EU Regulation concerning the Carriage of Dangerous Goods by Rail (RID) The European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN) The International Maritime Dangerous Goods Code (IMDG), published by the International Maritime Organisation (IMO) Restricted Articles Regulations published by the International Air Transport Association (IATA) International Civil Aviation Organisation (ICAO) Regulations.

The UN system

The UN model regulations (Recommendations on the Transport of Dangerous Goods, commonly known as the orange book) establishes a basic system for the safe transport of dangerous goods. The system is designed to reduce the risk of serious incidents involving dangerous goods and the impact of such incidents when they do occur.

Dangerous goods are substances that meet the criteria for one or more classes. The regulations stipulate that dangerous goods are: Classified (identified) according to their hazard(s) Packaged to the required standards Marked Labelled Documented The regulations also state that relevant personnel should be properly trained.

Classification

Classification is a fundamental part of the UN system incorporating: UN class UN packing group UN number Proper shipping name

Dangerous goods are firstly assigned to one of nine hazard classes, known as UN classes, according to their primary hazard. Secondly, an assessment is made of the relative hazard of a substance within the same class and the substance is assigned to one of three packing groups. Each substance is then allocated a substance identification number which is designed to allow identification of the substance in transit. These code numbers are commonly known as UN numbers. The UN recommends that UN numbers appear on all transport documents and are

This content is only valid at the time of download - 30-09-2021 17:53 14 of 72 displayed on packages, containers, vehicles, along with a description of the substance called the proper shipping name.

Diagram 3 below shows how the nine UN hazard classes are numbered and sub-divided into divisions. The Regulations also contain rules on identifying the hazards and danger of the substances. Each class (and sometimes division) is therefore assigned a hazard symbol.

Class 1 Explosives

(Divisions - 1.1, 1.2, 1.3, 1.4, 1.5, 1.6 (1.6 not used in the UK)

Class 2 Gases

Division 2.1 Flammable gases

Division 2.2 Non-Flammable, compressed gases

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Class 3 Flammable liquids

Class 4 Flammable solids

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Division 4.2 Substances liable to spontaneous combustion

Division 4.3 Substances that in contact with water emit flammable gases.

Class 5 Oxidising substances

Division 5.1 Oxidising substances other than organic peroxides

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used until 2009

Division 5.2 Organic peroxides

Class 6 Toxic and infectious substances

Division 6.1 Toxic substances

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Class 7 Radioactive material

Category I, Category II, Category III and fissile material (capable of nuclear explosion)

Class 8 Corrosive substances

Class 9 Miscellaneous dangerous substances and articles

This content is only valid at the time of download - 30-09-2021 17:53 19 of 72 Diagram 3 United Nations class, division and hazard symbol

United Nations packing groups

The UN system identifies substances in a particular class or division according to the degree of danger. This is known as the packing group:

Packing group I: high danger Packing group II: medium danger Packing group III: minor danger

Goods are assigned to one of these groups based on the criteria. Packing groups do not apply to explosives (class 1), gases (class 2), organic peroxides (class 5.2), infectious substances (class 6.2), radioactive material (class 7) or self-reacting substances found in class 4.1. Instead there are special packaging and transport provisions for these materials.

The international agreements for the carriage of dangerous goods require packaging to be of a design type certified by a national competent authority. This involves testing the packaging to ensure its suitability for the carriage of certain dangerous goods. Such packaging is often referred to as a type-approved or UN-certified and is marked in particular ways, prefixed by the UN logo and followed by a set of codes that detail the standard of packaging.

UN number

Once a product has been assigned to an appropriate hazard class and packing group, it is assigned a UN number. The United Nations (UN) number is a means of identifying a chemical substance or an article containing a chemical. A list of UN numbers can be found in the current version of the Dangerous Goods Emergency Action Code List.

Several other organisations publish lists of additional numbers for use in their countries, or by a particular mode of transport:

This content is only valid at the time of download - 30-09-2021 17:53 20 of 72 The North American 8000 series, published by the International Air Transport Association (IATA) includes entries for some additional substances and articles that are to be transported by air.

The North American 9000 series also contains many additional numbers for substances and articles not otherwise classified for transport.

UN numbers also divide into four types. Precedence is given to the most specific entry that is applicable to the substance, mixture, preparation or article in the following order:

Single entries for well-defined substances or articles (for example, UN 1090 ACETONE) Generic entries for well-defined groups of substances or articles (for example, UN 1133 ADHESIVES containing flammable liquids or UN 1263, PAINT) Specific entries not otherwise specified (N.O.S.) covering a group pf substances or articles of a particular chemical or technical nature (for example, UN 1987 ALCOHOLS, N.O.S. or UN 1224, KETONES, LIQUID, N.O.S) Generic entries not otherwise specified (N.O.S.) covering a group of substances or articles meeting the criteria of one or more classes or divisions (for example, UN 1993 FLAMMABLE LIQUIDS, N.O.S. or UN 1992, FLAMMABLE LIQUID, TOXIC, N.O.S)

Proper shipping name

The name immediately following the UN number is the proper shipping name (PSN) and is the one that should be quoted on packages, tanks and in documentation. Even when the substance is known by more than one name, it is the PSN that should always be used. Examples include UN 1035 Ethane and UN 1993 Flammable liquid, N.O.S.

Segregation

There are rules on segregation as a means of keeping incompatible goods apart from one another using a barrier or intervening space. Chemicals must be segregated when either stored or transported to reduce the likelihood of them mixing if an accident occurs. This is an essential element of the safe system of work designed to prevent fires, explosions and the release of harmful gases, etc. The rules for sea transport (i.e. International Maritime Dangerous Goods IMDG code) are more strict than for road or rail.

The regulations contain segregation tables that can be referenced to see if two materials can be transported together, or if conditions apply if they are transported in the same shipment. These tables can be a useful guide for establishing some common incompatibilities, or where additional hazards will result from chemicals mixing (for example, a flammable material and an oxidising agent which could result in a fire if mixed).

Documentation

This content is only valid at the time of download - 30-09-2021 17:53 21 of 72 Slightly different rules apply when describing the load on the documentation that must accompany consignments of dangerous goods for each mode of transport. However, they are all based on the same principles. These documents are a valuable means of identifying the load and hence obtaining hazard information that can be used to develop the incident response plan.

The documentation should contain the following information for each dangerous substance, material or article being carried:

United Nations number preceded by the letters ‘UN’ Proper shipping name (PSN) supplemented with the technical name in brackets, when applicable Packing group for the substance preceded by the letters ‘PG’ (e.g. PG II), or the initials corresponding to the words ‘packing group’ for other languages Total quantity of dangerous goods for different UN number, proper shipping name or packing group (shown as by volume or mass (weight) as appropriate) Number and description of the packages, when applicable Total quantity of dangerous goods contained in dangerous goods in machinery or equipment Name and address of the consignor (i.e. where it was sent from) Name and address of the consignee(s) (i.e. where it is going to); if this is not possible (e.g. a consignment with multiple delivery addresses) then the words ‘delivery sale’ may be shown instead.

There are special provisions for explosives (Class 1) and radioactive material (Class 7).

The most common form of transport document likely to be encountered is the dangerous goods note (DGN) accompanying the movement of dangerous goods by road. Since July 2009 and the removal of product-specific instructions in writing for the driver (commonly known and referred to as Tremcards®), which emergency responders used as a means of identifying the load, the DGN is the main means of identifying the contents of a vehicle carrying packaged dangerous goods.

Road transportation

Packaged goods transport labelling

Different regimes are used to placard and label dangerous goods transported in packages.

Following classification, the manufacturer or importer will be able to produce an appropriate label for the substance. For transport purposes, this label will include:

This content is only valid at the time of download - 30-09-2021 17:53 22 of 72 The designation of the product or its proper shipping name (PSN); this is the official description listed in the regulations for a particular UN number The UN number Appropriate hazard warning symbols

If a product is not specifically listed in the Regulations, or the hazardous properties and emergency response procedures for a solution or mixture differ significantly from those of the pure substance, then one of the generic (N.O.S.) entries must be used. In such cases, the PSN must be supplemented with the technical name of the goods. The technical name should be a recognised chemical name for the substance or substances which caused the product to be classified as hazardous. Normally not more than two ingredients are named (for example, gasoline and carbon tetrachloride mixture UN 1992 flammable liquid, toxic, N.O.S. or trimethyl gallium UN 2003 metal alkyl, N.O.S.).

Image 8 Transportation label for packaged methanol

There are different requirements for labelling products for supply and use, which are covered separately. However, for some containers the labels for transport and supply can be combined.

This content is only valid at the time of download - 30-09-2021 17:53 23 of 72 Image 9 A combined label for transport and supply

Combination packages

Packaged goods are usually transported in a combination package consisting of inner packages of a size intended for supply (usage), packed into an outer box convenient for transport.

Packages for transporting hazardous goods are required to be fit for purpose and be tested and marked with a UN symbol to show this (for example: 4G/Y25/S/03/GB/PRL271). For further information regarding packaging see HSE Packaging.

The inner package will be labelled for supply purposes, while the outer package will be labelled for carriage. Because the regulations for transport and supply of hazardous goods cover different hazards, the labels that have to be provided on each layer of the package can be different for each.

This can cause some confusion, particularly where the inner containers of a package may be labelled as toxic because of their potential to cause adverse effects with long-term exposure, while the outer containers may not be labelled at all because the product does not have an effect with short-term exposure.

This content is only valid at the time of download - 30-09-2021 17:53 24 of 72 Image 10 Combination package

Road transport regulations

The regulations concerning the carriage of dangerous goods by road apply from when the goods are being loaded on to a vehicle until they are removed. In some cases they apply until any receptacle containing dangerous goods and/or the vehicle itself has been cleaned to a set standard so that there is no risk from the original product. For example, the hazards associated with a receptacle containing flammable liquids such as petroleum products will be present even when the receptacle is empty due to flammable vapours remaining until it has been cleaned.

Duties are placed on different people. There are those consigning dangerous goods for carriage, vehicle operators, drivers and others such as those involved in the design and construction of vehicles. Many of the requirements in the regulations are placed on the operator of the vehicle, i.e., the person who has the management of the vehicle (has the vehicle operator's licence).

The requirements of the legislation only apply above certain quantity thresholds. These depend on whether the dangerous goods are being carried in packages, tanks or in bulk. The consignor of a load has a duty to classify the dangerous goods, in accordance with strict guidance, and correctly package and label them.

Before responsibility for the safe carriage of these goods passes to the operator of the vehicle, the consignor needs to fulfil further important requirements. They must:

Provide the operator with information Ensure that the rest of the transport chain; from the operator to the vehicle carrying the goods to the driver and the person who finally receives the consignment (the consignee) – has the necessary information to enable them to: Identify what is being carried and the hazards the goods pose

This content is only valid at the time of download - 30-09-2021 17:53 25 of 72 Ensure appropriate precautions are taken to prevent, as far as possible, any risk to the health and safety of anyone who might be affected by the carriage of the goods Respond quickly and effectively in the event of an accident involving the carriage of dangerous goods and, in particular, provide the information to the emergency services so that they can act appropriately.

Marking of packaged goods vehicles

The image below shows a vehicle that is used to transport dangerous goods in packages that is within the scope of the regulations by displaying plain orange placards at both the front and rear. While this is an indication that the vehicle is carrying dangerous goods, it gives no indication of their nature Further information regarding the load would need to be found on the driver’s delivery schedule, dangerous goods note (DGN) or on the packages themselves.

Image 11 Vehicle carrying packaged dangerous goods

Voluntary marking of packaged goods vehicles

Two examples of voluntary vehicle marking schemes are currently operated by transport carriers of dangerous goods in the UK with the agreement of the Health and Safety Executive, the Police Carriage of Dangerous Goods (CDG) Practitioners Forum and the Department for Transport.

Hazchem Emergency Response Service (HERS)

The HERS is a group of member carriers that use a central hub depot and satellite depots to transport packaged dangerous goods on pallets. This system displays a decal on the rear of its member vehicles showing the name of the scheme and a contact emergency telephone number. The telephone number can be used to access emergency advice, to potentially access details of what the vehicle is carrying (if the registration number is known) and to access clean-up arrangements already put in place.

This content is only valid at the time of download - 30-09-2021 17:53 26 of 72 Image 12 Hazchem Emergency Response Service (HERS) Decal used by the Hazchem Network palletised dangerous goods carriers in the

DHL Hazchem Emergency Response Service

A similar decal is displayed on the back and sides of vehicles used to transport dangerous goods These vehicles are sometimes used to carry radioactive materials but the Hazchem Emergency Response Service (HERS) decals are used when the vehicles are carrying packaged dangerous goods but not radioactive materials.

These decals will only be displayed if the vehicle is carrying dangerous goods of sufficient quantities that the vehicle is subjected to the requirements of the ADR Regulations. In other words, if the vehicle is carrying goods that fall under the limited quantity exemptions to ADR, or the vehicle is not carrying dangerous goods at all, then the decals will not be displayed.

This content is only valid at the time of download - 30-09-2021 17:53 27 of 72 Image 13 Hazchem Emergency Response Service (HERS) decal used by some DHL vehicles while carrying dangerous goods in the UK

This content is only valid at the time of download - 30-09-2021 17:53 28 of 72 Image 14 Type of vehicle used by DHL to transport packaged dangerous goods in the UK. The class 7 and ‘Radsafe’ labels would be

Placarding of road tankers and tank containers

Although the UK is a signatory to the international agreements on road transport movements (ADR) there are different requirements for placarding tankers and tank containers for purely domestic journeys (UK Hazchem). These do not apply to international movements of dangerous goods either starting or completing their journey in the UK.

Images 15 and 16 below illustrate the difference between the two systems.

Image 15 UK Hazchem placard Image 16 ADR placard

Table 21 Comparison of UK Hazchem and ADR placarding

This content is only valid at the time of download - 30-09-2021 17:53 29 of 72 Information UK Hazchem ADR

UN number Yes Yes

Hazard symbol Yes Yes

Emergency action code (EAC) Yes

Emergency telephone number Yes

Hazard identification number (HIN) Yes

UK Hazchem hazard warning panel

UK Hazchem hazard warning panels or placards used in the United Kingdom contain information on the hazardous substance being carried by the vehicle.

UK Hazchem hazard warning panels or placards are not the ADR hazard identification number (HIN), also known as the Kemler Code; this is a different warning placard. The main difference is the ADR HIN details the nature of the hazard presented by the goods as opposed to the actions to be taken when dealing with them.

Image 17 below shows a UK Hazchem hazard warning placard. The top-left section of the panel gives the emergency action code (EAC) that advises fire and rescue services on the actions to take if there is an accident. The middle-left section gives the UN substance identification number. The lower-left section gives the telephone number that should be called if special advice is needed. The warning symbol at top-right indicates the UN hazard class of the load. The bottom-right of the plate carries a company logo.

This content is only valid at the time of download - 30-09-2021 17:53 30 of 72 Image 17 UK Hazchem hazard warning panel

UK bulk vehicle placarding

Image 19 UK Hazchem hazard warning panel - single bulk load

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Image 19 above shows the signage for a bulk single load (in excess of three cubic metres). The detailed signage will be on the sides and rear of the vehicle.

Image 20 Single load in packages in a freight container

Image 20 above shows signage for a vehicle carrying dangerous goods in packages in a demountable freight container. In addition to orange panels on the front and rear of the vehicle, all sides of the container will have the standard warning symbols, according to the hazards posed by the load.

Image 21 Single load tanker

The image above shows a single load tanker. Note the variations in showing the key information.

This content is only valid at the time of download - 30-09-2021 17:53 32 of 72 Image 22 Multi load tanker

Image 22 above shows the signage for a multi load tanker. The main placard will state multi-load but the hazard symbol(s) will show the hazard(s) of the load. Each individual compartment of the tanker will have its own sign giving the UN number for the substance and the hazard symbol denoting its specific hazard.

European ADR vehicle bulk placarding

Image 23 Single bulk load showing ADR markings for a bulk single load

European ADR tanker or tank placarding

This content is only valid at the time of download - 30-09-2021 17:53 33 of 72 Image 24 Single load tanker showing ADR markings

Single load tanker

For tank vehicles carrying only one substance, as shown above, the identification numbers can be shown on the orange plates at the front and rear of the vehicle. Hazard warning symbols are located on each side of the vehicle and at the rear (as indicated).

Image 25 Bulk load tanker

This content is only valid at the time of download - 30-09-2021 17:53 34 of 72 Image 26 Tank vehicle carrying a multi load will display signage as shown above

Tank container

Vehicles carrying tank containers must display orange plates on each side of the tank, or tank compartments, giving hazard and substance identification numbers. A blank plate is displayed at the front and rear. Hazard warning symbols are located on each side of the compartment adjacent to each ADR placard.

Tank containers must have the identification numbers on the tank itself to remain in sight when the tank is offloaded from the vehicle.

Elevated temperature marking

Tank vehicles, tank containers, portable tanks, special vehicles or containers or specially-equipped vehicles or containers carrying elevated temperature substances are required under ADR to display an elevated temperature mark on both sides and at the rear for vehicles, and on both sides and at each end for containers, tank-containers and portable tanks. Image 27 below shows the elevated temperature marking displayed according to ADR,

Image 27 Elevated temperature marking

Environmentally hazardous substances marking

This content is only valid at the time of download - 30-09-2021 17:53 35 of 72 When required to be displayed in accordance with the provisions of ADR, containers, tank- containers, portable tanks and vehicles containing certain environmentally hazardous substances are to be marked with the environmentally hazardous substance mark shown below.

Image 28 Environmentally hazardous substances marking

Switch-loading of petrol and distillate fuels

Switch-loading is the terminology used to describe the practice of loading a distillate fuel (e.g. diesel or gas oil), into a tank compartment that has previously contained petrol. Switch-loading can also be practiced between petrol and kerosene but this practice is normally discouraged because of the risk of residual petrol (liquid or vapour) lowering the flash point of the kerosene.

In the UK the practice of switch-loading road tankers is very common, undertaken by perhaps as many as 95% of petrol/distillate fuel tankers to minimise unnecessary journeys (e.g. by discharging one load and returning with another). Compartments of tankers that have been switch-loaded will not only contain the liquid distillate product but also an amount of petrol vapour remaining from the previous load or loads.

Road tankers that transport petrol are designed and constructed for bottom loading with vapour recovery and in addition to the compartment ullage spaces, petrol vapour will be retained in the associated vapour manifold and pipework, together with small amounts of petrol in other associated pieces of equipment.

Distillate fuels have a greater density than petrol and in many cases a nominal full load of distillate will require a tanker to run with an empty or partially filled compartment, to ensure that the vehicle does not exceed its maximum authorised mass on the road.

Large volumes of petrol vapour will be retained in the empty and/or partially-filled compartments of a tanker carrying distillates in which petrol has been previously loaded. Even in compartments not previously loaded with petrol there is a risk that vapour will be present. This is due to the inter- compartment connection afforded by the vapour manifold and the vapour transfer valves, all of which are open during the bottom loading process. It is possible that a tanker may arrive at a site with a full load of diesel and leave with a full load of petrol vapour.

Where a mixed load of liquid products comprises petrol, diesel, kerosene or aviation fuels the tanker will be marked with the UN number of the product with the greatest hazard i.e. the lowest flashpoint. In the case of empty, uncleaned tanks, the tanker is marked as if it still contained the

This content is only valid at the time of download - 30-09-2021 17:53 36 of 72 original product. However, there are no specific marking provisions where the transport of a single substance with the residual vapour of a product with a greater hazard (lower flashpoint) is undertaken, even though this may present a similar hazard to that of an empty uncleaned tanker.

Under the current regulations, a compartment that was previously filled with petrol and then refilled with diesel and subsequently emptied of the diesel would have to be marked UN 1202 (diesel) to reflect the last load in the uncleaned tank, but in fact could be filled with petrol vapour.

These hazards are recognised by the petroleum industry and as a result it has become widespread practice in the UK for road tanker operators to retain the petrol marking (UN 1203) on tankers for a number of full loads of diesel or gas oil (UN 1202) after carrying petrol, to reflect the presence of the retained petrol vapour and the greater danger this may pose.

Actions for fire and rescue services

Fire and rescue services should be aware that, when dealing with incidents involving petrol/distillate tankers, any of the tank compartments may contain mixtures of distillate and petrol vapour. Therefore, all the tanks should be treated as if they contained petrol vapour until information to the contrary is obtained.

This also means that tanks may contain diesel/gas oil as the main load but may still be marked as petrol to better reflect the greater danger from any residual petrol vapours.

The emergency action code (EAC) for all such tankers should therefore be taken to be 3YE (indicating a possible public safety hazard beyond the immediate area of the incident) even though the emergency action code for the distillates will be 3Y and some tankers may still be marked as such.

As there are no movements of petrol/distillate tankers to and from Europe this will not be an issue for non-UK registered tankers (i.e. those marked with ADR hazardous identification numbers).

Registration, evaluation, authorisation and restriction of chemicals (REACH) Regulations

Registration, evaluation, authorisation and restriction of chemicals (REACH) is a European Union regulatory framework for chemicals, which came into force on 1 June 2007. REACH has several aims and puts greater responsibility on industry to manage the risks from chemicals and to provide safety information that will be passed down the supply chain.

REACH will require some 30,000 chemical substances to be registered over a period of 11 years, excluding the following;

Radioactive substances Substances under customs supervision

This content is only valid at the time of download - 30-09-2021 17:53 37 of 72 The transport of substances Non-isolated intermediates Waste Some naturally occurring low-hazard substances

The registration process requires anyone manufacturing more than one tonne per year of these substances within the EU, or importing this amount into the EU, to generate data for all chemicals produced or imported, whether on their own or in one or more preparations. This information must be registered with the European Chemicals Agency. The registrants must also identify appropriate risk management measures and communicate them to the users.

In addition, REACH will allow the further evaluation of substances where there are grounds for concern and foresees an authorisation system for the use of substances of very high concern. This applies to substances that cause cancer, infertility, genetic mutations or birth defects, and to those that are persistent and accumulate in the environment. The authorisation system will require companies to switch progressively to safer alternatives where a suitable alternative exists. All applications for an authorisation need to include an analysis of alternatives and a substitution plan where a suitable alternative exists. Current use restrictions will remain under the REACH system.

Rail transportation

All classes of hazardous substances are carried on the UK rail network (except in Northern Ireland). The carriage of dangerous goods regulations apply to rail transport, with detailed guidance coming from the Carriage of Dangerous Goods Manual (HSE).

The only exceptions to the regulations are:

Substances carried with the sole purpose of being used on, or by, the train (e.g. fuel) Radioactive materials; these have their own Regulations (Packaging Labelling and Carriage of Radioactive Material by Rail Regulations)

The regulations require that sufficient information is supplied with the load to ensure that all involved with the transportation process can:

Identify what is being carried Be aware of the potential hazards In the case of the fire and rescue service, respond quickly and efficiently

The information is supplied to the train operator and the rail infrastructure controller, therefore if there is an incident and the information cannot be obtained from the train driver, it can be obtained from the operator.

The information given includes:

This content is only valid at the time of download - 30-09-2021 17:53 38 of 72 Designation and classification of the dangerous goods UN number Packaging group Compatibility and division for explosives Consignor and consignee details Specialist advice Mass and volume of the: Package Tank, tank container, or tank wagon Bulk load in container or wagon Total consignment.

Containers, tank container, tank wagons and wagons must display relevant signage related to their contents, using the UK Hazchem system for UK-only journeys or the RID marking provisions for international journeys (these mirror those of ADR for road vehicles), as shown above.

Total operations processing system (TOPS)

The total operations processing system (TOPS) is a computerised system that enables Network Rail to keep a constant check on the position and availability of every rail vehicle on their system and provide specific information of the various loads that are being hauled.

It consists of a central computer system connected to regional control offices, marshalling yards and depots throughout the country. The system is based on a main computer, which is linked to input points at area freight offices throughout Network Rail.

From these control centres, details of all the wagon and freight details, whether they are loaded or unloaded, freight train movements and type of traffic conveyed are fed into the computer. On request by an incident commander via fire service control and Network Rail control office can obtain any specific information from the system, on any wagon or freight train and its cargo. Each wagon is clearly marked with an individual identification number on its side. This number will be recorded on the TOPS computer so that information on the load can be made readily available for operational staff in the event of an incident.

This content is only valid at the time of download - 30-09-2021 17:53 39 of 72 Image 29 Location of identification numbers and hazard warning plates on wagon

Additional tank wagon identification schemes

Tank wagons carrying certain classes of dangerous goods can be identified by specific colour schemes. For example, tank wagons carrying Liquefied petroleum gas (LPG) will have a white barrel with a horizontal orange stripe round the barrel at mid height. Tank wagons carrying flammable liquids are painted dove grey and the sole bars are painted signal red (sole bars are the two horizontal metal bars on which the bottom of the tank rests).

In addition, all wagons containing dangerous goods will have a Network Rail dangerous wagon label displayed on each side. This label indicates the class of substance being carried and the principal hazard that could be encountered. Containers that are hauled by rail are exempt from being labelled in this manner.

The emergency code for the label consists of a six digit number. The first four numbers are the substance identification number for the substance carried or the class, division and compatibility group in the case of explosives. The remaining two letters are referred to as the alpha code. This code has been allocated to firms and enables Network Rail to ascertain the telephone number that should be used to request specialist assistance in the event of an emergency.

This content is only valid at the time of download - 30-09-2021 17:53 40 of 72 Image 30 Example of tank wagon designed to carry LPG

Information available from the rail vehicle crew

The rail vehicle crew holds information on the specific details of each wagon and the details of their individual loads. This is recorded on an information sheet known as the consist. It will contain the following information:

Position of every wagon from front to rear Train identity number Locomotive identity number Wagon numbers Dangerous goods emergency codes UN number plus specialist advice contact code

It would be advisable for the incident commander to obtain the consist as it will provide immediate information on the type of loads being carried and give interim guidance on a course of action to follow until further information is secured either from TOPS or from a designated specialist adviser.

The 2018 Network Statement: Network Rail gives further information on Exceptional Transports and Dangerous Goods.

Irradiated fuel flasks

If an incident involving an irradiated fuel flask occurs, NAIR will be activated immediately. However, some operational priorities need to be considered whilst the NAIR scheme is instigated. For further information see National Operational Guidance: Health hazards.

This content is only valid at the time of download - 30-09-2021 17:53 41 of 72 Image 31 Irradiated fuel transport flask being loaded onto a train

Air transportation

Unlike road and rail transportation of hazardous materials, all air transport is classed as international and therefore is governed by international regulations and agreements.

The worldwide system used to control the transportation of dangerous goods by air is based on the same United Nation’s Emergency Response Guidebook (ERG) requirements placed on all other modes of transport. International requirements for the safe air transportation of radioactive material also relate to UN standards. Because of the particular nature of air transportation, restrictions on the type and quantities of dangerous goods transported are strictly enforced.

Worldwide harmonisation

Worldwide harmonisation of the transportation of dangerous goods by air is overseen by an agency of the UN. The principles of the international requirements are contained in the International Civil Aviation Organisation (ICAO) technical instructions and include:

Classification Identification (marking, labelling and documentation) Acceptability for air transport Packaging and packing Loading and stowage Information Training Reporting of incidents and accidents Inspection and investigation

International agreement

This content is only valid at the time of download - 30-09-2021 17:53 42 of 72 The Convention on International Civil Aviation (Chicago Convention) and its annexes set out the international standards and principles for air transportation throughout the world. Annex 18 to the Convention contains the principles applied to dangerous goods. They require that:

States ensure compliance with the technical instructions There must be inspection surveillance and enforcement procedures Dangerous goods accidents and incidents must be reported Dangerous goods accidents and incidents must be investigated ICAO technical instructions and IATA dangerous goods regulations The ICAO technical instructions are produced in English and are the source of the legal rules.

The International Aviation Transportation Association (IATA), the aviation trade organisation, publishes a set of Dangerous Goods Regulations that incorporate the ICAO technical instructions. The only real difference between the two documents is the order of the information, although the IATA document is more restrictive than the technical instructions. The IATA document is a field document and is more commonly referred to in aviation circles.

UK law

The UK’s legal obligations under the Chicago Convention are fulfilled by the following:

The Air Navigation Order 2016, which permits the making of regulations to control the carriage of dangerous goods by air.

The Air Navigation (Dangerous Goods) Regulations 2002 (As amended 2017) that contain detailed requirements and refer to the need for airlines to comply with the latest edition of the ICAO technical instructions.

The Air Navigation (Dangerous Goods) Regulations apply to:

Shippers Freight agents Handling agents Couriers The Post Office Passengers Operators

The regulations require the above operators and users to comply with the technical instructions and to have permission to carry dangerous goods from the Civil Aviation Authority (CAA).

Cargo aircraft

This content is only valid at the time of download - 30-09-2021 17:53 43 of 72 These aircraft are designed or modified for the carriage of cargo only, both in the under-floor hold and on the main deck. Aircraft specifically designed to carry cargo may have nose-opening or tail- opening cargo doors to allow loading of large or specialist cargoes. Other cargo aircraft have large main-cabin freight doors, usually positioned aft of the nose area on the port side.

Dangerous goods can be carried on cargo aircraft either in the under-floor holds or on the main deck. Those in the under-floor holds will be in passenger aircraft quantities, whereas those on the main deck will usually be cargo aircraft only items.

Passenger aircraft with under-floor holds (only)

These aircraft (examples include the Boeing 737, 747 and Airbus 3 series) are designed primarily for carrying passengers. Cargo (and baggage) will be carried in holds that are below the main deck (under floor). The introduction of wide-bodied passenger-carrying aircraft means there is a great deal of capacity in the under-floor holds for carrying cargo. Dangerous goods may be carried in the under-floor holds in passenger aircraft in limited quantities.

Passenger aircraft with holds on the same deck as passengers (combi-aircraft)

These aircraft have also been designed primarily for carrying passengers. There are two types:

The holds are on the same deck as the passengers The holds are on the same deck as the passengers and there are also under-floor holds

In aircraft with holds on the same deck as the passengers, the holds may be little more than areas of the cabin separated from the passengers by curtains. In others they may be surrounded by sealed bulkheads with access from outside the aircraft only or through doors in the cabin that are kept locked in flight. Aircraft with holds on the same deck as passengers have come to be known as combi-aircraft.

Dangerous goods in passenger aircraft quantities may be carried on combi-aircraft in under-floor holds and on the main deck holds. When dangerous goods are carried, the hold must be totally separated from passengers by a bulkhead. Some low-hazard dangerous goods (i.e. those that would not lead to a serious safety or health problem in the event of a leakage) may be carried in the main deck cargo hold on other types of combi-aircraft, with approval from the Civil Aviation Authority.

Convertible aircraft (quick change aircraft)

A number of aircraft are designed to be converted quickly so that during the day they can carry passengers and at night carry cargo; they are known as quick change (QC) aircraft. Dangerous goods can be carried on QC aircraft as permitted for passenger or cargo aircraft, depending on the configuration at the time

This content is only valid at the time of download - 30-09-2021 17:53 44 of 72 Principles of safe transportation of dangerous goods by air

According to the hazard posed by the substance, dangerous goods may be:

Carried on passenger and or cargo aircraft Restricted to cargo aircraft only Forbidden on both passenger and cargo aircraft (but exemption to carry may be possible) Totally forbidden in all circumstances Packaged: no bulk transportation Carried in limited quantities per package for passengers and cargo

Dangerous goods integral to the aircraft

Many systems and items of equipment on board an aircraft are considered to be hazardous materials; these include:

Aircraft equipment: Life rafts, aerosols Fire extinguishers Dry ice Batteries Alcohol Oxygen generators Perfumes and colognes Fuel, matches and lighters Passenger baggage

Packaging for transport by air

The requirements for packaging are similar to those required by ADR and the Chemicals (Hazard Information and Packaging for Supply) Regulations, except that packages must also take into account:

Temperature variations Pressure differences Vibration

Packages are therefore required to undergo the following tests:

Drop test Stacking test Leak-proof test (drums only) Hydraulic (pressure) test (drums only)

This content is only valid at the time of download - 30-09-2021 17:53 45 of 72 Marking and labelling

Packaged goods are marked and labelled in accordance with UN recommendations. Both primary and secondary hazard symbols are displayed if appropriate.

Where goods are designated as being excluded from passenger aircraft, an aircraft-specific CAO (cargo aircraft only) orange label must be displayed.

Image 32 Cargo aircraft-only label

Shipper’s declaration

All dangerous goods must be accompanied by a shipper’s declaration. The shipper’s declaration for dangerous goods can be distinguished from other flight documents by the red and white hatching on each side of the document. The declaration should contain the following information:

Proper shipping name UN number UN class, division and subsidiary risk(s) Packing group (if applicable) Packing instructions and type of packaging Net quantity and number of packages Radioactive materials must additionally carry the: Name or symbol of radionuclide Activity Package category and transport index

The image below shows an example of the shipper’s declaration, which is produced by the shipper. There should be one copy at the originating point with one other travelling with the dangerous goods.

This content is only valid at the time of download - 30-09-2021 17:53 46 of 72 Image 33 Shipper's declaration

Notification to the commander (NOTOC)

A special load form must be given to the commander of the aircraft, identifying the dangerous goods that have been placed on board in the cargo and where they have been loaded. This form is known as a notification to the commander (NOTOC) and must be on the aircraft in the possession of the commander. There should also be a copy of the NOTOC at the loading airport although, unlike the commanders copy, this is not a legal requirement.

Loading of dangerous goods

Packaged dangerous goods could be loaded into aircraft: As individual packages On pallets Within transport loading units (known as unit load devices (ULD))

This content is only valid at the time of download - 30-09-2021 17:53 47 of 72 Image 34 Example of an air transport unit load device

Image 34 above illustrates a typical unit load device (ULD). This refers to any type of container with an integral pallet, or an aircraft pallet, whether or not owned by an IATA member, and whether or not considered to be aircraft-equipped. These units interface directly with an aircraft loading and restraint system. Such units become an integral part of the aircraft structure when loaded.

If the labels on packages are not visible when they are on pallets or in ULDs, a red hatched tag showing the hazard classes present must be displayed on the outside of the pallet or ULD. The cargo aircraft only (CAO) label must also be displayed or be visible where appropriate.

Loading restrictions

Packaged dangerous goods:

Must not be stowed in the passenger cabin or on the flight deck Must not be on passenger aircraft if labelled 'cargo aircraft only' (CAO) Cargo aircraft only (CAO) packages must be accessible in flight Packages of liquids with orientation arrows must be upright Packages must be secured to prevent movement Damaged packages must not be loaded Incompatible dangerous goods must not be stowed to allow interaction Most explosives must be segregated from other dangerous goods Some types of radioactive materials must be separated from persons Magnetized material must be loaded so that the compass cannot be affected.

Incidents

Incidents can be categorized into those:

On the ground Occurring during flight

This content is only valid at the time of download - 30-09-2021 17:53 48 of 72 If an incident involving dangerous goods occurs during the flight, the aircraft’s commander will refer to Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods. This publication is produced by ICOA and provides emergency response details including an in-flight checklist for each dangerous substance category hazard. For incidents on the ground, the airport fire service will usually deal with the incident, supported by the airport’s local fire and rescue service.

As a requirement of Annex 18 to the Chicago Convention, all incidents must be investigated.

See National Operational Guidance: Transport.

Maritime transportation

Much of the cargo transported by sea may be classed as dangerous. Incidents involving dangerous substances at sea can be divided into two main areas:

Incidents off-shore Incidents in harbour

The main difference between these two types of incident is that for an incident located in a harbour, the hazardous materials adviser (HMA) must liaise with the harbour master when advising on the operational plan.

Vessels carrying dangerous goods will display a red warning flag between sunrise and sunset. Between sunset and sunrise (and during the day in restricted visibility) vessels will display an all- round, uniform and unbroken red light visible for at least two nautical miles in good night time conditions when moored or anchored.

International Maritime Dangerous Goods Code (IMDG) code

Transporting dangerous goods by sea is an international industry and is governed by an international standard; the International Maritime Dangerous Goods Code (IMDG).

The Code is used by all areas of the shipping industry that carries dangerous goods, and covers all aspects of their transportation, from the construction of the vessels to limiting quantities of substances carried.

IMDG has three volumes:

Volume 1 includes general provisions such as definitions, training requirements, etc. Volume 2 includes the dangerous goods list and limited quantities exceptions The supplement contains the emergency schedules and medical first aid guidance; it also contains two sections that are of specific interest to the hazardous materials adviser (HMA)

This content is only valid at the time of download - 30-09-2021 17:53 49 of 72 Marine pollutants

A number of dangerous substances are also identified as substances harmful to the marine environment; these are known as marine pollutants. Substances classified as marine pollutants are carried in packages or transport containers identified with a marine pollutant symbol. Amendment 23 of the IMDG introduced a new marine pollutant symbol of a dead fish and a tree, which replaced the previous triangle containing a dead fish and crossed lines.

Image 35 New (right) and previously used (left) marine pollutant symbols

Emergency schedule (EMS)

This is the emergency schedule for dealing with incidents involving dangerous goods that are on fire or have been spilled.

Fire

A series of generic tables with the prefix F give guidance on the specific hazards of a substance when involved in fire and the firefighting tactics that should be employed in various locations on the ship.

Spillage

A series of generic tables with the prefix S give guidance on the hazards associated with various spills, personal protection and tactics for different sized packages and spills in various locations on the ship.

Medical first aid guidance (MFAG)

This section contains a flow chart to assist in the initial assessment of a casualty and refers the reader to generic numbered tables for specific conditions. In each case, casualty signs and symptoms are described and detailed treatments given. In many cases the treatments are significantly more involved than for normal first aid and are designed to preserve life whilst at sea, using the vessel’s on board medical facilities. This information can prove to be of considerable value when attempting to assess whether the casualty has been exposed to a particular substance.

This content is only valid at the time of download - 30-09-2021 17:53 50 of 72 However, the guidance given under EMS and MFAG is designed for use when the vessel is at sea and to assist the survival of the ship and casualties whist awaiting help. As a result, some of the tactics and procedures outlined, such as ditching the material overboard, may not be appropriate when the ship is in port.

The EMS is reproduced as a section in Chemdata. When accessing Chemdata for incidents involving ships, the user should ensure they refer to the sections on emergency schedules. This information is not only essential when formulating a plan but also will give an understanding of the actions that may have been taken by the ship’s crew prior to the arrival of the fire and rescue service.

Bulk storage of hazardous substances

The bulk storage of hazardous substances presents fire and rescue service personnel with specific problems, which are:

Quantities of substances stored Variety of substances being stored Variety of storage media Proximity of other bulk storage of hazardous substances (for example, at Buncefield there were approximately 29 bulk storage tanks and three pipelines) Size of the consequence area in terms of the plume, firefighting media run off, potential proximity of residential areas, etc.

The Health and Safety Executive has issued regulations and approved codes of practice for aspects of the storage of hazardous substances. The regulations and approved codes of practice require that the owner/occupier carry out a detailed risk assessment on the premises storing hazardous materials, and subsequent safety systems be implemented. It is recommended that the hazardous materials adviser refers to these documents for details on safety systems.

The safety systems are based on the assessment of the risks from:

Release of dangerous substances Ignition sources Separation of product Elimination or reduction of risks from dangerous substances through: Ventilation Control of ignition Separation of product Fire resistance of the storage media Fire reaction

This content is only valid at the time of download - 30-09-2021 17:53 51 of 72 Emergency Action Code (EAC)

On arrival at an incident, emergency responders may have to make rapid decisions and actions, the consequences of which may determine the success of the operations carried out. However, information gathering is time consuming and it is often necessary for responders to act only on the information immediately available.

The emergency action code (EAC) (also known as the Hazchem code) is designed to cover the first vital step and gives an immediate indication of any actions that could be taken should it be necessary to proceed immediately without waiting for reference materials or expert advice.

Once any immediate action has been taken to save life, protect the environment and prevent the incident escalating, the next phase can involve more detailed information from the operator or driver, the company, paperwork from the vehicle cab and various data sources.

There is more information on EAC in the latest version of the Dangerous Goods Emergency Action Code list book. But the code can be explained as follows:

This content is only valid at the time of download - 30-09-2021 17:53 52 of 72 Image 18 Interpretation of the emergency action code

The firefighting extinguishing medium is determined by reference to the first character of the EAC as follows:

1. Denotes coarse water spray 2. Denotes fine water spray 3. Denotes normal foam i.e. Protein based foam that is not alcohol resistant 4. Denotes dry agent – water should not to come into contact with substance

Where the second character of the EAC is ‘S’, ‘T’, ‘Y’ or ‘Z’ normal firefighting clothing is appropriate (i.e. self-contained, open circuit, positive pressure, compressed air breathing apparatus (BA) conforming to BS EN 137 worn in combination with fire kit conforming to BS EN 469, firefighters’ gloves conforming to BS EN 659 and firefighters’ boots).

Where the second character of the EAC is ‘P’, ‘R’, ‘W’ or ‘X’, liquid-tight chemical protective clothing (CPC) conforming to BS 8428 should be used, in combination with breathing apparatus (BA) specified as above are to be used.

An ‘E’ following the first two characters of an EAC indicates that there may be a public safety hazard outside the immediate area of the incident and that the following actions should be considered:

People should be warned to stay indoors with all doors and windows closed, preferably in rooms upstairs and facing away from the incident Ignition sources should be eliminated and any ventilation stopped Effects may spread beyond the immediate vicinity; all non-essential personnel should be instructed to move at least 250 metres away from the incident Police and fire and rescue service incident commanders should consult each other and a product expert, or with a source of product expertise The possible need for subsequent evacuation should be considered, but it should be remembered that in most cases it will be safer to remain in a building than to evacuate

Where the EAC contains a ‘P’, ‘S’, ‘W’ or ‘Y’ there is a danger that the substance can be violently or explosively reactive or that there could be:

A violent or explosive decomposition of the material involved, including ignition or friction The ignition of a flammable gas or vapour cloud (this danger exists for all flammable gases and liquids with a flash point below 60°C) The rapid acceleration of combustion due to the involvement of an oxidiser A reaction with water, which is itself violent and may also evolve flammable gases.

In some cases, a higher level of personal protection is required than the one indicated on the emergency action code (EAC) displayed on a vehicle or tank. In the list of EACs. This is indicated by

This content is only valid at the time of download - 30-09-2021 17:53 53 of 72 the presence of an additional personal protection (APP) code of ‘A’ or ‘B’ in column four of the EAC list. This information also appears on the Chemdata database entries for the material.

Code letter A indicates that fire kit (to the specified standards as indicated in the EAC list) should be worn in combination with gas-tight chemical protective clothing (CPC), again as specified. The fire kit is intended to protect against one or more of the following additional hazards that are indicated in the list by the appropriate character(s) in brackets, following the A:

(c) Liquefied gas with a boiling point below -20°C

(fg) Flammable gas

(fl) Flammable liquid

(cf) Liquefied flammable gas with a boiling point below -20°C

(h) The substance may be carried above 100°C

(co) Oxidising gas with a boiling point below -20°C

(!) The substance may have a particularly deleterious effect on chemical protective clothing (CPC)

An APP code letter B indicates that the chemical protective clothing (CPC) should be gas-tight conforming to BS EN 943 part two, in combination with the breathing apparatus (BA), as specified in the EAC list.

When directed to apply additional personal protection code (APP) code A, the most vulnerable areas of potential exposure will probably be the hands and feet. Appropriate hand protection for the particular hazard should be taken into consideration when conducting the risk assessment of any task to be undertaken. Structural firefighting kit is specified as tunic, over-trousers, fire hood and firefighting gloves, all conforming to the relevant British or European standard.

Most firefighting gloves cannot be worn with gas-tight suits. Even if crews are wearing gloves that meet the additional requirements of additional personal protection code (APP) code A, they will still not be fully protected against the extremely low temperatures encountered with cryogenic substances

Consider the following when selecting the most appropriate personal protective equipment (PPE) ensemble:

Physical properties of the substance Form (gas/vapour, liquid, solid) Toxicity and/or infectivity Concentration levels

This content is only valid at the time of download - 30-09-2021 17:53 54 of 72 Quantity of product involved or potentially involved Likelihood of direct contact Type of hazardous material incident (fire, potential fire, leak or spillage) Limitations of personal protective equipment (PPE) on identified tasks Nature and extent of proposed actions Location within the environment (open air, enclosed compartment or structure) Prevailing weather conditions Potential decontamination strategy

Consider the following when personnel are wearing chemical protective clothing in potentially flammable or explosive atmospheres:

A risk/benefit assessment should be carried out to establish if it is necessary to enter the risk area in chemical protective clothing Always have firefighting media and covering sprays immediately available The build-up of electrostatic charge on the fabric with the potential to ignite a flammable atmosphere or cause an explosion Sparks can also be caused by stones or grit embedded in the soles of boots and the use of metal tools In circumstances where the relative humidity is below 25%, the likelihood of sparks is increase Wetting the suit before entry to reduce electrostatic build up

ADR hazard identification numbers (HIN) or ‘Kemler Code’

The hazard identification number consists of two or three figures indicating the following hazards:

Table 22 Hazard identification numbers

No. Hazard

2 Emission of gas due to pressure or chemical reaction

3 Flammability of liquids (vapours) and gases or self-heating liquid

4 Flammability of solids or self-heating solid

This content is only valid at the time of download - 30-09-2021 17:53 55 of 72 No. Hazard

5 Oxidising (fire-intensifying) effect

6 Toxicity

7 Radioactivity

8 Corrosivity

9 Risk of spontaneous violent reaction

Duplication of a figure (e.g. 55) indicates an intensification of that particular hazard.

Where the hazard associated with a substance can be adequately indicated by a single figure, this is followed by a zero.

A hazard identification number prefixed by letter X indicates that the substance will react dangerously with water.

Table 23 below shows the meanings of hazard identification number combinations:

(*Water must not be used except by approval of experts

Table 23 Hazard identification number meanings

Number Meaning

20 Asphyxiant gas or gas with no subsidiary risk

22 Refrigerated liquefied gas, asphyxiant

223 Refrigerated liquefied gas, flammable

225 Refrigerated liquefied gas, oxidising (fire intensifying)

23 Flammable gas

238 Gas, flammable corrosive

239 Flammable gas, which can spontaneously lead to violent reaction

This content is only valid at the time of download - 30-09-2021 17:53 56 of 72 Number Meaning

25 Oxidising (fire-intensifying) gas

26 Toxic gas

263 Toxic gas, flammable

265 Toxic gas, oxidising (fire-intensifying)

268 Toxic gas, corrosive

28 Gas, corrosive

Gas, corrosive, oxidisingFlammable liquid that reacts with water, emitting 285 30flammable gases

Flammable liquid (flash-point between 23°C and 60°C inclusive) or flammable liquid or solid in the molten state with a flash point above 60°C, 30 heated to a temperature equal to or above its flash point, or self-heating liquid

323 Flammable liquid that reacts with water, emitting flammable gases

Flammable liquid that reacts dangerously with water, emitting flammable X323 gases

33 Highly flammable liquid (flash point below 23°C)

333 Pyrophoric liquid

X333 Pyrophoric liquid, which reacts dangerously with water*

336 Highly flammable liquid, toxic

338 Highly flammable liquid, corrosive

X338 Highly flammable liquid, corrosive, which reacts dangerously with water*

This content is only valid at the time of download - 30-09-2021 17:53 57 of 72 Number Meaning

339 Highly flammable liquid that can spontaneously lead to violent reaction

Flammable liquid (flash point between 23°C and 60°C inclusive), slightly 36 toxic or self-heating liquid toxic

362 Flammable liquid, toxic, which reacts with water, emitting flammable gases

Flammable liquid, toxic, which reacts dangerously with water, emitting X362 flammable gases*

368 Flammable liquid, toxic, corrosive

Flammable liquid (flash point between 23°C and 60°C inclusive), slightly 38 corrosive or self-heating liquid, corrosive

Flammable liquid, corrosive, which reacts with water, emitting flammable 382 gases

Flammable liquid, corrosive, which reacts dangerously with water, emitting X382 flammable gases*

39 Flammable liquid, which can spontaneously lead to violent reaction

40 Flammable solid, or self-reactive substance, or self-heating substance

Solid that reacts with water, emitting flammable gas, or flammable solid 423 which reacts with water, emitting flammable gases or self-heating solid which reacts with water, emitting flammable gases*

Solid that reacts dangerously with water, emitting flammable gases, or flammable solid that reacts dangerously with water, emitting flammable X423 gases, or self-heating solid that reacts dangerously with water, emitting flammable gaseFlammable solid, in the molten state at an elevated temperatures*

43 Spontaneously flammable (pyrophoric) solid

This content is only valid at the time of download - 30-09-2021 17:53 58 of 72 Number Meaning

Spontaneously flammable (pyrophoric) solid that reacts dangerously with X432 water, emitting flammable gases*

44 Flammable solid, in the molten state at an elevated temperature

446 Flammable solid, toxic in the molten state, at an elevated temperature

46 Flammable or self-heating solid, toxic

462 Toxic solid that reacts with water, emitting flammable gases

X462 Solid that reacts dangerously with water, emitting toxic gases*

48 Flammable or self-heating solid, corrosive

482 Corrosive solid that reacts with water, emitting corrosive gases

X482 Solid that reacts dangerously with water, emitting corrosive gases*

50 Oxidising (fire-intensifying) substance

539 Flammable organic peroxide

55 Strongly oxidising (fire-intensifying) substance

556 Strongly oxidising (fire-intensifying) substance, toxic

558 Strongly oxidising (fire-intensifying) substance, corrosive

Strongly oxidising (fire-intensifying) substance, which can spontaneously 559 lead to violent reaction

56 Oxidising substance (fire-intensifying), toxic

568 Oxidising substance (fire-intensifying), toxic, corrosive

58 Oxidising substance (fire-intensifying), corrosive

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Oxidising substance (fire-intensifying) that can spontaneously lead to violent 59 reaction

60 Toxic or slightly toxic substance

606 Infectious substance

623 Toxic liquid, which reacts with water, emitting flammable gases

63 Toxic substance, flammable (flash point between 23°C and 60°C inclusive)

Toxic substance, flammable (flash point between 23°C and 60°C inclusive), 638 corrosive

Toxic substance, flammable (flash point not above 60°C inclusive), which can 639 spontaneously lead to violent reaction

64 Toxic solid, flammable or self-heating

642 Toxic solid, which reacts with water, emitting flammable gases

65 Toxic substance, oxidising (fire-intensifying)

66 Highly toxic substance

663 Highly toxic substance, flammable (flash-point not above 60°C inclusive)

664 Highly toxic substance, flammable or self-heating

665 Highly toxic substance, oxidising (fire-intensifying)

668 Highly toxic substance, corrosive

669 Highly toxic substance that can spontaneously lead to a violent reaction

68 Toxic substance, corrosive

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Toxic or slightly toxic substance, which can spontaneously lead to a violent 69 reaction

70 Radioactive material

78 Radioactive material, corrosive

80 Corrosive or slightly corrosive substance

Corrosive or slightly corrosive substance, which reacts dangerously with X80 water*

823 Corrosive liquid which reacts with water, emitting flammable gases

Corrosive or slightly corrosive substance, flammable (flash point between 83 23°C and 60°C inclusive)

Corrosive or slightly corrosive substance, flammable (flash point between X83 23°C and 60°C inclusive), which reacts dangerously with water*

Corrosive or slightly corrosive substance, flammable (flash point between 839 23°C and 60°C inclusive), which can spontaneously lead to violent reaction

Corrosive or slightly corrosive substance, flammable (flash point between X839 23°C and 60°C inclusive), which can spontaneously lead to violent reaction and which reacts dangerously with water*

84 Corrosive solid, flammable or self-heating

842 Corrosive solid which reacts with water, emitting flammable gases

85 Corrosive or slightly corrosive substance, oxidising (fire-intensifying)

Corrosive or slightly corrosive substance, oxidising (fire-intensifying) and 856 toxic

86 Corrosive or slightly corrosive substance, toxic

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88 Highly-corrosive substance

X88 Highly-corrosive substance, which reacts dangerously with water*

Highly-corrosive substance, flammable (flash-point between 23°C and 60°C 883 inclusive)

884 Highly-corrosive solid, flammable or self-heating

885 Highly-corrosive substance, oxidising (fire-intensifying)

886 Highly-corrosive substance, toxic

X886 Highly-corrosive substance, toxic, which reacts dangerously with water*

Corrosive or slightly-corrosive substance, which can spontaneously lead to a 89 violent reaction

Environmentally hazardous substance; miscellaneous dangerous 90 substances

99 Miscellaneous dangerous substance carried at an elevated temperature

Packaging

Hazardous materials containers range in size from small vials and jars used in laboratories, through larger packages and transport containers holding many tonnes, to site storage tanks and vessels that can hold many thousands of tonnes.

All hazardous materials containers have a number of design features. The cause of most hazardous materials incidents is a failure of one or more of the requirements; for example, a container in fire is unable to withstand additional external temperature and internal pressure, leading to a breach.

Design features:

This content is only valid at the time of download - 30-09-2021 17:53 62 of 72 Compatibility – must not react with its contents Suitability for the physical form (solid, liquid, gas) of the hazardous material for the temperatures and pressures the container may be subjected to Ability to withstand reasonably expected external stressors such as knocks or being dropped during transport Have access to add and/or remove the hazardous materials Meet certain legal requirements Meet regular testing, inspection and maintenance or replacement requirements

If the correct container has been used and it is intact, the substance is in a ‘controlled’ state and no risk is posed to people, infrastructure or the environment. Incidents involving hazardous materials are fundamentally driven by containment failure and the way in which failure occurs. This leads to the hazardous materials becoming ‘uncontrolled’ and introduces risk.

Containment failure can only occur following a ‘stressor’ being applied to the container. There are a limited number of stressors that can affect containment:

Thermal Chemical/biochemical/photochemical Mechanical Human or animal

Once containment failure has become inevitable, the manner in which containment fails can also have significant effect on the outcome and scale of the incident. Again, a container can breach in a limited number of ways; these will lead to a specific type of release that will affect the scale and hazards:

A useful mnemonic to help in the gathering of hazardous materials information is SEDITION:

Stressor – What is causing or threatening to cause the containment to fail?

This content is only valid at the time of download - 30-09-2021 17:53 63 of 72 Escapes – Where are the breaches in the containment system? Dispersal – Where is the substance going, or potentially going to go? Impingement – What is the substance going to come into contact with? Troubles – What are the potential negative effects? reactION - What reactions could take place?

Pressure receptacles

Pressure receptacles and their closures should be designed, calculated, manufactured, tested and equipped to withstand all conditions, including fatigue, to which they will be subjected during their normal use and during normal conditions of carriage.

Intermediate bulk containers

An intermediate bulk container (IBC) is a container constructed of moulded plastic, fibreglass, steel or plywood with steel reinforcing and is used for storage and transportation of goods. IBCs may range in size but are generally between 700 mm and 2000 mm in height. The length and width of an IBC usually depends on the country's standard pallet dimension. They may have pallet-like bases so that they can be easily lifted using forklift trucks. IBCs can contain powdered or liquid chemicals.

Image 36 Examples of IBCs

Drums

A drum is a flat-ended or convex-ended cylindrical packaging made from metal, fibreboard, plastics, plywood or other suitable materials. This also includes packaging of other shapes (e.g. round, taper-necked or pail-shaped). Wooden barrels and portable cans are not covered by this definition.

This content is only valid at the time of download - 30-09-2021 17:53 64 of 72 Image 37 Example of metal drum used for transporting hazardous materials

Bags

Hazardous substances typically found in bags include agrochemicals of a quantity of up to 1 tonne.

Portable tanks, multi-element gas containers (ISO tanks)

A portable tank is a multimodal tank used for the carriage of explosives (UN class 1) and other dangerous goods in UN classes 3 to 9. The portable tank includes a shell fitted with service equipment and structural equipment necessary for the carriage of dangerous substances. The portable tank can be filled and discharged without removing its structural equipment. It has

This content is only valid at the time of download - 30-09-2021 17:53 65 of 72 stabilising members external to the shell, and can be lifted when full. It is designed primarily to be loaded onto a transport vehicle or ship and is equipped with skids, mountings or accessories to allow mechanical handling. Tank-vehicles, tank-wagons, non-metallic tanks and IBCs are not considered to fall within the definition for portable tanks.

Examples of portable tanks (ISO tanks)

Image 38 Non-pressure transit tankers

Non-pressure tankers are used for transporting liquids and gases that do not need to be stored under pressure. There are various models, ranging from single-load tankers to multi-load tankers. Tankers will not show any warning signage when empty.

Image 39 Non-pressure tank – nitric acid

Image 39 above shows a non-pressure tank containing Nitric Acid>70 per cent. Note the added protection to prevent accidental damage to the structure of the tank, which is a good indication that the tanker carries a high-consequence load.

This content is only valid at the time of download - 30-09-2021 17:53 66 of 72 Image 40 Example of a non-pressure, stainless steel, multi-compartment tanker

Image 40 above shows a 30,000-litre, non-pressure, stainless steel, multi-compartment tanker that can carry a variety of substances at different times, but only compatible loads during any single journey.

Image 41 Example of an ADR tank designed for the transportation of gas oil or black oil

Image 41 above shows a 33,000-litre insulated ADR tank designed for the transportation of gas oil or black oil. It has a top-fill loading system via a gantry and side access ladder with handrail. This container has fibreglass insulation with aluminium panels.

Vacuum-operated waste tanks

This content is only valid at the time of download - 30-09-2021 17:53 67 of 72 Vacuum-operated waste tanks

Image 42 above shows a vacuum-operated tank; note the external strengthening ribs that prevent the tank collapsing when the vacuum is applied. Details of the specifications regarding vacuum operated waste tanks can be found in Chapter 6.10 of ADR Volume II

Pressure tanks

Image 43 Example of a pressure tank designed for carrying liquefied petroleum gas

Image 43 above shows a typical pressure tank designed for carrying liquefied petroleum gas.

Cryogenic liquid tanks

A cryogenic receptacle is a transportable, thermally-insulated pressure receptacle for refrigerated liquefied gases.

This content is only valid at the time of download - 30-09-2021 17:53 68 of 72 Image 44 Examples of cryogenic liquid tanks and associated equipment

Bulk containers

Typically this term applies to containers designed for use on road vehicles and in shipping, such as ISO-containers. The term container does not cover conventional packaging, IBCs, tank-containers or vehicles.

Image 45 Examples of stacked shipping containers

Image 45 above shows a shipping container stacked on the dockside. Containers could be used to transport dangerous goods that are not declared on the manifest, so care should be taken when opening containers.

An example of non-UN approved packaging used to transport dangerous goods are the oak barrels used to transport whisky.

Bulk tanks

The various tanks in use are designed to store different types of substances. The following list shows the design criteria for hydrocarbon oils:

Floating roof tanks, containing:

Class A (flash point below 228°C) hydrocarbon fuels Class B (flash point between 228 and 656°C)

Non-pressure tanks, containing:

Class A (flash point below 228°C) Class B (flash point between 228 and 656°C)

This content is only valid at the time of download - 30-09-2021 17:53 69 of 72 Class C (flash point above 656°C)

Fixed roof tanks, containing:

Class A (flash point below 228°C) Class B (flash point between 228 and 656°C) Class C (flash point above 656°C)

Pressure fixed roof tank:

Class A (flash point below 228°C) hydrocarbon fuels

Spherical pressurised tank:

Liquefied petroleum gas (LPG), liquid nitrogen gas (LNG)

Horizontal pressure tank:

LPG, LNG

Refrigerated storage tank:

LPG, ethylene, LNG, similar hydrocarbons, and ammonia

Image 46 Overview of a tank farm

Labelling and signage

Storage facilities for hazardous materials must apply signage to the premises in accordance with the Notification and Marking of Sites Regulations 1990 (NAMOS).

Pipelines

This content is only valid at the time of download - 30-09-2021 17:53 70 of 72 On-shore and off-shore pipelines are an economic way of transporting large volumes of hazardous and non-hazardous substances across, into and out of the United Kingdom. Pipelines have long been used to transport crude oil to refineries and to shipping terminals, and petroleum and its derivatives are still the main fluids moved by pipeline. Pipelines are increasingly used for transporting various industrial materials and products, in particular those of the chemical industry. Progress has also been made with transporting solid materials as slurries in water or other fluids.

The advantages of pipeline transport include reduced costs, easing congestion on roads, maintaining delivery round the clock irrespective of season or weather conditions, eliminating contamination during transport, removing dangerous fuel cargoes from the roads and reducing stocks held in crowded areas. Pipelines are classified as cross-country or local; in law a cross- country pipeline is one whose length exceeds 16km.

Safety considerations

The safety of pipelines is overseen by the Gas and Pipelines Unit, part of the Health and Safety Executive (HSE). The unit is the enforcing authority for:

Upstream natural gas transmission and distribution networks Gas storage facilities On-shore major hazard pipelines Offshore pipelines Other associated high-hazard sites

The HSE has issued guidance on the safety of pipelines in the form of L82 ‘A Guide to the Pipelines Regulations’. These regulations cover all pipelines but of particular interest to fire and rescue services are major accident hazard pipelines.

A major accident hazard pipeline is defined as a pipeline that conveys a dangerous fluid with the potential to cause a major accident.

The regulations and guidance notes give best practice advice on:

The requirement for emergency shut-down valves The major accident prevention document Arrangements for emergency plans

Marking of pipelines

Details of the types of markers used to indicate the location of pipelines can be found on the linewatch website.

Operational considerations for pipeline incidents

This content is only valid at the time of download - 30-09-2021 17:53 71 of 72 The Health and Safety Executive has issued a document that includes information on:

Hazards and effects of pipeline failures Fire and explosion Toxic effects Blast effects and projectiles Cryogenic effects Asphyxiation Noise

The incident commander and hazardous materials adviser will consider these as part of the risk assessment process.

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